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E-commerce

Dwolla

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Dwolla is a US bank transfer and ACH payments API that runs mostly server to server, with an optional JavaScript drop in component and bank verification flows often paired with Plaid.

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Overview

What does Dwolla do?

What Dwolla is

Dwolla is a bank transfer and ACH payments platform operated by Dwolla Inc. in Des Moines, Iowa, in the United States. It is mainly an API that moves funds between bank accounts on behalf of software platforms, with an optional drop in component for embedding flows.

Data and cookies collected

Because Dwolla works server to server, the browser footprint is small. The optional drop in component and the dashboard set functional cookies needed to operate, while the substantive processing of bank account and identity data happens through the API. Bank verification is often handled with a partner such as Plaid.

GDPR and ePrivacy implications

The functional cookies used to deliver a transfer the user requested are generally exempt from the consent rule in the ePrivacy Directive. The processing of bank and identity data rests on contract, on legal obligations for financial rules, and on legitimate interests for fraud prevention.

Consent requirements

Consent is generally not required for the payment transaction itself because it is strictly necessary to provide the service the user asked for. If a platform adds analytics or marketing around the Dwolla flow, those non essential cookies need prior consent.

International data transfers

Dwolla processes data in the United States, so European platforms carry out a transfer to a third country. This should be covered by Standard Contractual Clauses, a transfer impact assessment, and supplementary safeguards, with attention to any bank verification partner involved.

Practical compliance steps

Sign a data processing agreement with Dwolla, document the US transfer and any verification partner, and disclose the functional cookies of the drop in and dashboard. Obtain end user consent for using their data as required by the Dwolla platform agreement and keep a clear privacy notice.

Compliance

Dwolla and the GDPR

Legal basis
Performance of a contract under Article 6(1)(b) GDPR for executing bank transfers, legal obligation under Article 6(1)(c) GDPR for financial and anti money laundering rules, and legitimate interests under Article 6(1)(f) GDPR for fraud prevention
Risk level
medium
Applicable regulations
GDPR, ePrivacy Directive, and applicable US financial regulations

Impact assessment (DPIA)

Risk on the embed side is limited because Dwolla is mainly a backend API that sets only functional cookies. A DPIA should focus on the bank account and identity data flowing to the US, the role of bank verification partners such as Plaid, and the financial nature of the data.

Sample text for your banner

We use Dwolla to move funds between bank accounts when you request a transfer. Dwolla operates mainly as a backend service and uses only functional cookies needed to deliver it. Your bank account details are processed to complete the payment you have asked us to make.
Cookies and trackers

What Dwolla sets and contacts

Tracking method
Server to server REST API with an optional JavaScript drop in component and bank verification flows, setting only functional cookies on the embed and dashboard
Server location
United States
Cookieless mode available
Yes
Data transferred outside the EU
Personal data is processed by Dwolla Inc. in the United States, a third country under the GDPR. Where European data is involved, transfers rely on the Standard Contractual Clauses together with supplementary measures.

Cookies set (3)

NameTypeDurationPurpose
Drop in session cookieThird-partySessionMaintains the state of the Dwolla drop in component while the user completes a flow
Dashboard session cookieFirst-partySessionKeeps the user authenticated in the Dwolla dashboard for the duration of the session
Functional preference cookieFirst-party1 yearStores basic functional and security preferences for the Dwolla interface

Third-party domains contacted (5)

  • dwolla.com
  • api.dwolla.com
  • cdn.dwolla.com
  • dashboard.dwolla.com
  • accounts.dwolla.com
Questions

Frequently asked questions about Dwolla

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What cookies does Dwolla set?

Dwolla is mainly a backend API, so its browser footprint is small. The optional drop in component and the dashboard set functional cookies needed to operate the interface, rather than analytics or marketing cookies on the merchant page.

Is consent required for Dwolla?

Consent is generally not required for the payment transaction itself because the functional cookies are strictly necessary to deliver the transfer the user requested. Consent applies only if a platform adds non essential analytics or marketing around the flow.

What is the legal basis for Dwolla?

Processing rests on performance of a contract under Article 6(1)(b) for executing bank transfers, legal obligation under Article 6(1)(c) for financial and anti money laundering rules, and legitimate interests under Article 6(1)(f) for fraud prevention.

Does Dwolla transfer data to the US?

Yes. Dwolla Inc. processes data in the United States, so European platforms carry out a transfer to a third country. This should be covered by Standard Contractual Clauses and supplementary safeguards, including any bank verification partner such as Plaid.

Is a DPIA needed for Dwolla?

A DPIA is advisable because Dwolla processes bank account and identity data and transfers it to the US, even though the browser footprint is small. The assessment should cover the financial data, the US transfer and any verification partner involved.

How do I implement Dwolla compliantly?

Sign a data processing agreement with Dwolla, document the US transfer and any verification partner, and disclose the functional cookies of the drop in and dashboard. Obtain end user consent for using their data as required by the Dwolla platform agreement.

What are alternatives to Dwolla?

Alternatives for bank transfer and ACH payments include Stripe ACH, Plaid with a processor, GoCardless for direct debit, and Modern Treasury. Each differs in server locations, cookie behaviour and transfer mechanisms that should be reviewed individually.

How do I update my cookie policy for Dwolla?

Add a short Dwolla entry that explains it is mainly a backend API and lists the functional cookies of the drop in and dashboard with their purposes and durations. Note the US data transfer and update the entry if you embed more of the Dwolla flow.

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